endstream endobj 560 0 obj <. If you are not checking invoices carefully against your contract terms and conditions, your jurisdiction may be paying more that it should; or, in the case of a revenue-generating contract, your jurisdiction may be receiving less than it should. Other important aspects to consider are the audit period, access to records and personnel, format of records, time needed, failure-to-produce penalties and notification requirements (planned versus surprise reviews). Federal Register Publication Vol 85 No. After reviewing and analyzing data, managers can follow up and review more information, identify issues and resolve them. There are several techniques you could use to identify vendors to audit. Then you can compile this information into a data-friendly format, like a spreadsheet. The American Rescue Plan will deliver $350 billion for eligible state, local, territorial, and Tribal governments to respond to the COVID-19 emergency and bring back jobs.. Look for those in the coming weeks. Conducting a survey can be as simple as sending out an email or using a free online survey tool. Within that broad term, common types of vendor audits (ranging from a less-narrow scope to a more-narrow scope) include process compliance audits, financial compliance audits, regulatory compliance audits, general compliance audits, and fraud audits. Justifying and documenting the selection of vendors, including: (1) that a vendor is responsive to the requirements outlined in the procurement, (2) responsible, (3) not debarred from doing business with the federal government, and (4) offering a reasonable, competitive cost, based on cost or price analysis completed by the municipality. We also are grateful for a group of dedicated county attorneys, including Bob Shaver, Glynn Rollins, Anne Marie Tosco, Aimee Scotton, and Russ Burrell, who provided helpful feedback on the draft policies. Consistently applied. To promote appropriate and effective use of ARPA funds, jurisdictions should: Jurisdictionsshould also develop evidence-based methods of measuring performance and project goals to make sure that grantees meet those expectations. Some page levels are currently hidden. 11246. This course is targeted to finance and management staff of smaller and mid-sized units that will be taking the standard allowance and spending most, if not all, of their ARP/CSLFRF as revenue replacement. For example, a municipality may have an engineering and construction firm contracted to build a new community center and wants to use the same firm to perform citywide water and sewer infrastructure projects as permitted by the CLFRF. WebThe Department of Education posted final requirements on ARPA ESSER in July 2021. Those requirements include ensuring that entities receiving Federal financial assistance from the Treasury do not deny benefits or services, or otherwise discriminate Wherever practicable, such records should be collected, transmitted, and stored in open and machine-readable formats. Treasurys implementing regulations, 31 CFR part 22, and the Department of Justice (DOJ) regulations, Coordination of Non-discrimination in Federally Assisted Programs, 28 CFR part 42, provide for the collection of data and information from recipients (see 28 CFR 42.406). Secure websites use HTTPS certificates. If a local government partners with another government, nonprofit, or other private entity to carry out an ARP/CSLFRF award project, it must follow the subaward process. endstream endobj 166 0 obj <> endobj 167 0 obj <> endobj 168 0 obj <>stream Chapel Hill, NC27599-3330 This includes setting specific requirements and expectations, providing an audit timeline, including when and where you will visit, who you will interview, and which documents you will need. The particular industry, the types of goods or services involved, the size and complexity of the contract, and the applicable regulatory requirements are just a few factors that can increase an organizations risk of fraud, waste and abuse. Additional controls that your organization should implement include written policies that explicitly identify appropriate allocation methods, accounting standards and principles, compliance monitoring checks for program income calculations, and records. When initiating an audit it is important to inform the vendor exactly which personnel and/or processes you will be auditing. Once the data has been transformed into auser-friendlyformat, it can be used in a variety of ways to assist with future procurements and other business decisions. Salaries and Expenses: In general, certain employees wages, salaries, and covered benefits are an eligible use of SLFRF award funds. hb```f``rb`e``_ B,``nAxsYd.(3b(|lzx=g3@7^L5b0\aO0 5wtt 1f 9WcrBe`.ymqcBr5v*r VvH3q/1iC U These risk assessments may include factors such as prior experience in managing Federal funds, previous audits, personnel, and policies or procedures for award execution and oversight. Data is everywhere, and every function a government performs can generate valuable data. Direct questions related to design and construction procurement to the Attorney Generals Office. Maintain open and direct communication with grantees. Regulatory compliance audits determine whether the vendor is following all of the laws and regulations relevant to the goods and services they provide (e.g., environmental regulations). clarified that funds made available under the American Rescue Plan Act (ARP) Coronavirus State and Local Fiscal Recovery Funds (CSLFRF) are subject to federal procurement requirements outlined in the Uniform Administrative Requirements, Cost Principles, and Audit Requirements for Federal Awards (Uniform Guidance), found at Title 2 of the Code of Federal Regulations, Part 200 (2 CFR 200). Recipients should note that SLFRF funds available under the revenue loss eligible use category generally may be used to meet the non-federal cost-share or matching requirements of other federal programs. The jurisdiction became suspicious, researched the vendor and found no registration information on file with the Secretary of Commonwealth. Procurement and contracting requirements are in place as best practices to mitigate the risk of fraud, waste, or abuse of federal funds and are designed to ensure that federally funded contracts are competitive and fair.[3] To start, here is a summary list of UG policies and their triggers. For supply contracts, for example, jurisdictions should verify that the vendor delivered the correct items in good condition and in the correct quantities. ARPA-funded projects must also adhere to North Carolina state law, WebDepending on the site host organizations procurement requirements, a formal solicitation process may be needed to purchase and install charging infrastructure. When was the last time your client revised their procurement contracts? Top-requested sites to log in to services provided by the state. To comply with this requirement, a local government must adopt and implement an Eligible Use Policy. Simply having a contract, however, does not ensure that a vendor will always bill at the agreed-upon rates, deliver the correct quantity or quality of materials, or perform the necessary activities required in the contract or by law. Now that you understand some specific techniques for visualizing and analyzing data, we encourage you to apply these techniques to procurements or other business decisions facing your jurisdiction. BenfordsLaw is best applied to large data sets (at least several hundred records) of naturallyoccuringnumbers with some connection, such as population data, income tax data or scientific data. Thus, the jurisdiction created a ready market for a single vendor without ensuring that drivers were receiving a fair price for the towing and storage services. Please see 2 CFR Part 200, Subpart E regarding the Cost Principles for more information. If you are still unclear about the requirements for your particular source of funding, we recommend that you contact the grantor or federal funding entity for clarification. There is no sure-fire method to uncover vendor fraud; therefore, it is the audit teams responsibility to remain alert and practice professional skepticism throughout the engagement. %%EOF It also must be generally recognized as ordinary and necessary for the proper and efficient performance of the ARP/CSLFRF grant award. Our confidential hotline is for public employees and individuals with Chapter 30B procurement questions. After contracting with the vendor, however, the local jurisdiction began receiving large quantities of supplies that it had not ordered. hWoHWcORPKt.u8 -fA zA^%hq0)`Q9^2 B $BJ*'xdg.|vOhRRFa)`q:e8^0^0^0^0^ 6fn?iTDuHG?=t1Ax twx3Oy!/%G}KoW%0!,k69\=nl Local governments should review the requirements, compare them to their current policies and procedures, and consult with legal counsel to evaluate. In addition, we recommend that all ARPA awardees review 2 CFR Part 200 Subpart D, as this section describes the requirements most applicable to local governments. Identifying the key vendor personnel is also an important part of the audit. Any acquisition and maintenance of equipment or real property must also be in compliance with relevant laws and regulations. WebARPA established the Coronavirus State and Local Fiscal Recovery Fund (CSLFRF), which is a a program that provides funding over a two-year period to all states, counties, and If you are used to having a financial statement audit, a single audit can be much more comprehensive. The public expects that the local jurisdiction protected their interests, including ensuring that the vendor is qualified and that the towing charges are reasonable; and vendors expect open and fair competitive processes when a local jurisdiction contracts for a service that it needs. Determine whether the contract allows the vendor to bill for the items listed on the invoice. BenfordsLaw is a mathematical observation about the frequency distribution of the first digits within a set of naturally occurring numbers. The first step in implementing a vendor audit program is determining who to audit. procurement policies pursuant to 2 CFR 200.317 as well as comply with the procurement standards set forth at 2 CFR 200.321 through 2 CFR 200.323, and 2 CFR 200.327. Additionally, ARPA funds are subject to oversight by certain state and federal agencies, including the Massachusetts OIG. Update: On January 6, 2022, the U.S. Department of the Treasury issued the Final Rule, which governs the eligible uses of Coronavirus State and Local Fiscal Recovery Funds (SLFRF) under the American Rescue Plan Act (ARPA).The Final Rule makes several key changes to the Interim Final Rule, including expanding the eligible uses of The executive order requires that every goods or services contract or agreement must incorporate an auditing provision permitting the government to audit the vendors books, records and other compilations of data relative to the performance of any provision or requirement of the contract or agreement. Federal procurement rules not applicable to certain ARPA-funded projects Tuesday, August 30, 2022. Outlier analysis, in its simplest form, compares different data points in order to identify data that stands out from the rest. Make sure the vendor is legitimate, responsible, has acceptable references and is properly registered to conduct business in Massachusetts. Incorporate by reference any federal rules that apply to the grant award. Financial compliance audits examine whether the vendor is billing appropriately. Equipment and Real Property Management. Mass.gov is a registered service mark of the Commonwealth of Massachusetts. Maintaining records sufficient to detail the history of procurement. Once you have access, you can use the data to inform your decisions and manage risks. To ensure that the cost items within an eligible project are proper, a local government must adopt and implement an Allowable Costs and Cost Principles Policy. Did you know reporting is not the only requirement for use of American Rescue Plan Act (ARPA) funds? Federal Uniform Guidance rules apply as well. Uniform Guidance? Never heard of it? Dont worry, weve got you covered. The team should consider gaining direct access to the vendors systems to facilitate its review. 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